Technical Support Document (TSD) for the 

Base Year Inventory 

For the 

Lyons 

2008 Lead NAAQS Nonattainment Area 

Submitted December 2014 by the 

Pennsylvania Department of Environmental Protection 

TSD Prepared April 2015 by 

Jessica L. Fry 

Office of Air Monitoring and Analysis, 3AP40 

U.S. Environmental Protection Agency, Region 3 

1650 Arch Street 

Philadelphia, Pennsylvania 19103 

Reviewed by Alice H. Chow, Associate Director 

Office of Air Monitoring and Analysis (3AP40) 
I. Introduction 

The purpose of this document is to provide a technical summary of the Office of Air 

Monitoring and Analysis (OAMA) review of the emissions inventories submitted with 

the Pennsylvania State Implementation Plan (SIP) Revision: Attainment Demonstration 

and Base Year Inventory, Lyons Nonattainment Area (NAA) for the 2008 Lead NAAQS. 

Under the Clean Air Act (CAA) sections 172(c)(3) states are required to submit 

emissions inventory information for all relevant sources for the areas that are designated 

nonattainment. The Pennsylvania Department of Environmental Protection (PADEP) has 

submitted a 2011 Base Year Inventory for the Lyons 2008 Lead NAAQS Nonattainment 

Area in order to fulfill the CAA requirements. Any questions pertaining to this technical 

summary should be directed to Alice H. Chow, Associate Director, Office of Air 

Monitoring and Analysis, at 215-814-2144 or via email at chow.alice@epa.gov. 

II 2011 Base Year Inventory 

Under section 172(c)(3) states are required to submit a comprehensive, accurate, 

current accounting of actual emissions from all sources (point, nonpoint, nonroad, and 

onroad) in the nonattainment area. This inventory contains actual annual emissions of 

lead. The base year inventory (typically one of the years in which the area was 

designated as attaining the standard) includes emissions estimates from stationary point 

and nonpoint sources. There are no onroad and nonroad source emissions in the NAA, 

mainly due to the ban on leaded gasoline in highway vehicles. Another source of mobile 

lead emissions are airports and landing strips. The NAA does not contain any of these 

sources. The areas in Berks County that are included in the NAA are Kutztown Borough, 

Lyon Borough, Maxatawny Township, and Richmond Township. 

PADEP submitted a 2011 inventory for the point sources in the NAA. EPA 

guidance for emissions inventory development provides that actual emissions should be 

used for purposes of the base year inventory. There are three sources oflead emissions in 

the NAA, the East Penn Manufacturing Company's Richmond Township Facility, the 

East Penn Manufacturing Company's Kutztown Facility and McConway &Torley 

Kutztown Foundry. PADEP requires larger emitting facilities to report production 

figures and emission calculations annually. Throughput data are multiplied by emission 

factors based on source classification codes (SCC) to develop emission estimates. 

For the nonpoint source emissions, also known as "area sources," PADEP 

submitted EPA's 2011 NEI v2. To calculate nonpoint values for the portion of Berks 

County included in the NAA, PADEP used county data apportioned by population, of 

which 4.1% of the population of Berks County is included in the NAA. 

OAMA staff reviewed the results, procedures, and methodologies for the SIP base 

year, and found them to be acceptable.